Privacy Statement
Suply HotSpot LLC (together with its affiliates, “Suply
HotSpot”, “we”, “us”, and “our”) respects individual privacy and values the
confidence of its clients, customers, employees, and business partners. Suply
HotSpot complies with the principles of lawfulness, fairness, transparency,
purpose limitation, data minimization, accuracy, storage limitation, integrity,
confidentiality, lawfulness of processing, notice, choice, onward transfer,
security, access, rectification, erasure, portability and enforcement required
under applicable laws, rules and regulations, including the GDPR.
This Privacy Statement (the “Statement”) sets forth the
privacy principles that Suply HotSpot follows.
- Scope
This Statement applies to personal information received by Suply
HotSpot in any format, including electronic, paper, or verbal.
- Privacy Principles
- The privacy principles of Suply HotSpot are:
- Lawfulness, Fairness, and Transparency
- When Suply HotSpot collects personal information, it will be
processed lawfully, fairly, and in a transparent manner in relation to the data
subject.
- Purpose Limitation
- When Suply HotSpot collects personal information, it will be
collected for specified, explicit, and legitimate purposes and not further
processed in a manner that is incompatible with those purposes.
- Data Minimization
- When Suply HotSpot collects personal information, it will be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. Accuracy relevant and limited to what is necessary in relation to the purposes for which it is processed.
- Accuracy
- When Suply HotSpot collects personal information, it will be
accurate and, where necessary, kept up to date; reasonable steps will be taken
to ensure that personal information that is inaccurate, having regard to the
purposes for which they are processed, is erased or rectified without
unreasonable delay.
- Storage Limitation
- When Suply HotSpot collects personal information, it will be
kept in a form which permits identification of data subjects for no longer than
is necessary for the purposes for which the personal information is processed.
- Integrity and Confidentiality
- When Suply HotSpot collects personal information, it will
take measures designed to protect against unauthorized or unlawful processing
and against accidental loss, destruction or damage.
- Lawfulness of Processing
- Any and all processing will be done lawfully. Suply HotSpot
will process personal information only if and to the extent that at least one
of the following applies: (1) the data subject has given consent to the
processing of his or her personal information for one or more specific
purposes; (2) processing is necessary for the performance of a contract to
which the data subject is a party or in order to take steps at the request of
the data subject prior to entering into a contract; (3) processing is necessary
for compliance with a legal obligation to which the data controller is subject;
(4) processing is necessary in order to protect the vital interests of the data
subject or of another natural person; (5) processing is necessary for the
performance of a task carried out in the public interest or in the exercise of
official authority vested in the controller; and (6) processing is in the
legitimate interests pursued by Suply HotSpot or by a third party.
- Information Collected
- As you interact with Suply HotSpot, there may be
opportunities for you to provide us with your information. Additionally, we may
collect certain information about you as further described below.
- We may also obtain information from other sources and
combine that with information we collect from you. For example, we may collect
information about you from third parties, including, but not limited to, our
affiliates, identity verification services, and credit bureaus.
- The types of information that Suply HotSpot collects about
you may include, but are not limited to:
- Contact
information (such as name, address, city, state and ZIP code, age or date
of birth, occupation, email address and telephone number);
- Information
about your connected devices (such as mobile phone, computer, or tablet)
and how you interact with our services, apps, and websites (such as IP
address, browser type, unique device identifier, cookie data, and
associated identifying and usage information);
- Demographic
information (such as gender and date of birth);
- Marketing
and business profile information;
- Business
contact information, including names, job titles, email address and phone
number, for employees or other business representatives;
- Payment
and financial information; and
- Photographs and videos such as those that you may submit to aid in product, retailer and vendor discovery on our online platform.
- How We Use and Disclose Information
We use and disclose personal information you provide to us
as described to you at the point of collection. We also use and transfer
personal information from or about you:
- to
respond to your inquiries and fulfill your requests, such as to send you
documents you request or e-mail;
- to
send you important information regarding our relationship with you,
changes to our terms, conditions, and policies and/or other administrative
information;
- for
the purpose for which the information was collected, for example, to
facilitate orders for products and to otherwise provide our services to
you;
- for
our business purposes, such as marketing new products, events, and
services, data analysis, audits, developing new products, events, or
services, operating or enhancing our website, improving our products,
events, and services, identifying usage trends, providing products,
events, and services, maintaining customer/client relationships, improving
the quality, safety, and security of our products, events, and services,
administering your account(s), troubleshooting, supporting electronic
signature, customizing and improving communication content, evaluating
product, event, or service performance, providing customer support, and
determining the effectiveness of our website;
- with
other users of our services, as you may request;
- to
our third party service providers who provide services such as website
hosting and moderating, mobile application hosting, data analysis,
infrastructure provision, credit card processing, IT services, e-mail
services, marketing services, auditing services, and other services, in
order to enable them to provide services;
- to
verify your information and authenticate payments and process orders, such
as disclosing certain financial and other information you provide to Suply
HotSpot to third parties that provide credit reporting, payment or order
fulfillment services;
- to a
third party in the event of any reorganization, merger, sale, joint
venture, assignment, transfer, or other disposition of all or any portion
of our business, assets, or stock (including in connection with any
bankruptcy or similar proceedings); and
- when
we otherwise have your consent.
In addition, we use and disclose personal information as we
believe to be necessary or appropriate: (a) as permitted by applicable law,
including laws outside your country of residence; (b) to comply with any legal
process; (c) to respond to requests from public and government authorities,
including public and government authorities outside your country of residence;
(d) to enforce our website Terms of Service; (e) to protect our operations or those of
any of our affiliates; (f) to protect our rights, privacy, safety, or property,
and/or that of our affiliates, you, or others; and (g) to allow us to pursue
available remedies or limit the damages that we may sustain.
We also use and disclose information that is not in
personally identifiable form (such as anonymized, masked or de-identified
information) for any purpose. If we combine information that is not in
personally identifiable form with information that is (such as combining your
name with your geographical location), we will treat the combined information
as personal information as long as it is combined.
- Choice
- Suply HotSpot will give individuals the opportunity to
affirmatively and explicitly consent (opt in) to the disclosure of certain
sensitive personal information to a third party or the use of the personal
information or sensitive personal information for a purpose other than the
purpose for which it was originally collected or subsequently authorized by the
individual. Suply HotSpot will provide individuals with reasonable mechanisms
to exercise their choices in regard to personal information
- Security
Suply HotSpot will take reasonable steps to protect the
personal information in its possession from loss, misuse, unauthorized access,
disclosure, alteration, and destruction, and will take precautions with regard
to the nature of the data and the risks of the processing, to preserve the
security of the data and, in particular, prevent its alteration and damage or
access by non-authorized third parties. Suply HotSpot has put in place
technical, physical, and organizational procedures and security measures
designed to safeguard and secure the personal information from destruction,
loss, alteration, unauthorized access or disclosure, or other forms of
unauthorized or unlawful processing commensurate with the risks posed by the
particular type of processing, the nature of the personal information and in
accordance with applicable law and guidelines, if any, promulgated by
authorities having jurisdiction therefor, and taking into consideration the
cost of implementing such measures. Suply HotSpot cannot guarantee the security
of personal information on or transmitted via the Internet.
Suply HotSpot will comply with the General Data Protection
Regulation (“GDPR”) and other applicable local laws, rules and regulations with
respect to data breach disclosure and notification.
- Access
Upon request by the individual, if required by applicable
law, Suply HotSpot will grant individuals reasonable access to their personal
information. Such access may include: (1) confirmation as to whether or not
personal information concerning him or her are being processed; (2) the
purposes of the processing; (3) the categories of personal information
concerned; (4) the recipients or categories of recipient to whom the processing
data have been or will be disclosed, in particular recipients in third
countries or international organizations; (5) if possible, the period for which
the personal information will be stored, or, if not possible, the criteria used
to determine that period; (6) the existence of the right to request from Suply
HotSpot rectification or erasure of personal information or restriction of
processing of personal information concerning the data subject or to object to
such processing; (7) the right to lodge a complaint with a supervisory
authority; (8) information about the source of the data, if not directly from
the data subject; (9) whether the personal information will be subject to
automated processing, including profiling and, if so, the logic and potential
consequences involved; and (10) if the data is transferred to a third country
or international organization, information about the safeguards that apply.
- Rectification
If the data subject requests, personal information collected
by Suply HotSpot will be corrected based on information provided by the data
subject. Where necessary, Suply HotSpot will take steps to validate the
information by the data subject to ensure that it is accurate before amending
it.
- Erasure
If the data subject requests, their personal information
collected by Suply HotSpot will be erased without undue delay provided that one
of the following applies: (1) the personal information is no longer necessary
for the purposes for which it was collected; (2) the data subject withdraws
consent and there is no other legal ground for processing; (3) if required by
applicable law, the data subject objects to the processing of the personal
information; (4) the personal information have been unlawfully processed; (5)
the personal information has to be erased for compliance with a legal obligation
of Suply HotSpot; or (6) where the personal information was relevant to the
data subject as a child.
- Portability
If required by applicable law, upon the data subject’s
request, their personal information collected by Suply HotSpot will be provided
to them in a structured, commonly-used and machine readable or the personal
information transferred to another party.
- Enforcement
Suply HotSpot will use a self-assessment approach to verify
compliance with this Statement and periodically verify that the Statement is
accurate, comprehensive for the information intended to be covered, prominently
displayed, implemented and accessible, and in conformity with applicable law.
Suply HotSpot encourages interested persons to raise any
concerns using the contact information provided in this Statement. Suply
HotSpot will investigate and attempt to resolve any complaints and disputes
regarding use and disclosure of personal information in accordance with this
Statement. Any employee of Suply HotSpot that Suply HotSpot determines is in
violation of this Statement will be subject to disciplinary action up to and
including termination of employment.
Suply HotSpot will (1) provide recourse to data subjects
with respect to enforcement of this Statement; (2) provide follow up procedures
for verifying that the attestations and assertions Suply HotSpot has made about
its privacy practices are true; and (3) remedy problems arising from the
failure of Suply HotSpot to comply with this Statement.
- International Data Subjects
While this Statement applies to personal information
generally, the local laws, rules and regulations of jurisdictions that are
applicable to Suply HotSpot (“Local Laws”) may require standards which are
stricter than this Statement and, in such event, Suply HotSpot will comply with
applicable Local Laws. Specific privacy policies may be adopted to address the
specific privacy requirements of particular jurisdictions. Your personal
information may be stored and processed in any country where we have facilities
or service providers. Irrespective of which country your personal information
is transferred, we would only share your personal information under a ‘need to
know’ basis. In these circumstances we will, as required by applicable law,
ensure that your privacy rights are protected by organizational, technical,
contractual and/or other lawful means.
- EU Data Subjects
In the European Economic Area and Switzerland (“EU”),
“Personal Data” is defined very broadly and includes any information about a
natural person, who can be identified, directly or indirectly, from data that
we hold about them or from data that is combined with other information. EU
data protection law requires us to have a legal basis before processing any
Personal Data about you. The legal bases for us processing your Personal Data
for the above purposes may be because: (i) you have provided your consent; (ii)
it is necessary to for the performance of a contract with you; (iii) the
processing is necessary for our compliance with a legal obligation; or (iv) the
processing is in our legitimate interests. To the extent provided by applicable
law, you may withdraw any consent you previously provided to us, or object at
any time on legitimate grounds, to the processing of your Personal Data. In
some circumstances, withdrawing your consent to Suply HotSpot’s use or
disclosure of your Personal Data will mean that you cannot take advantage of
certain Suply HotSpot products or services.
We may transfer your Personal Data outside the EU to the
United States or any country that Suply HotSpot or its service providers may
have operations. Such countries do not have the same data protection laws as
the EU. Any transfer of your personal information will be subject to a European
Commission approved contract (as permitted under the General Data Protection
Regulation) that is designed to help safeguard your privacy rights and give you
remedies in the unlikely event of a misuse of your personal information. To
obtain a copy of the such safeguards please contact us.
Under the General Data Protection Regulation you have a
number of important rights free of charge. In summary, those include rights to:
- Fair
processing of information and transparency over how we use your use
personal information
- Access
to your personal information and to certain other supplementary
information that this Statement is already designed to address
- Require
us to correct any mistakes in your information which we hold
- Require
the erasure of personal information concerning you in certain situations
- Receive
the personal information concerning you which you have provided to us, in
a structured, commonly used and machine-readable format and have the right
to transmit those data to a third party in certain situations
- Object
at any time to processing of personal information concerning you for
direct marketing
- Object
to decisions being taken by automated means which produce legal effects
concerning you or similarly significantly affect you
- Object
in certain other situations to our continued processing of your personal
information
- Otherwise
restrict our processing of your personal information in certain
circumstances
For further information on each of those rights, including
the circumstances in which they apply, see the Guidance from the UK Information
Commissioner’s Office (ICO) on individuals rights under the General Data
Protection Regulation (or other relevant guidance).
If you would like to exercise any of those rights, please
email us at support@SuplyHotSpot.com with
the following:
- Enough
information to identify you
- Proof
of your identity and address
- The
information to which your request relates
- How to Complain
The General Data Protection Regulation also gives you right
to lodge a complaint with a supervisory authority, in particular in the EU
state where you work, normally live, or where any alleged infringement of data
protection laws occurred.
- Dispute Resolution
In compliance with this Statement, Suply HotSpot commits to resolve complaints about the privacy, collection and use of personal information. Persons with inquiries or complaints about this Statement are encouraged to first contact Suply HotSpot.
- Changes to this Statement
This Statement may be amended from time to time, consistent
with the requirements of applicable law. A notice will be posted by Suply
HotSpot on Suply HotSpot’s Internet website located at www.SuplyHotSpot.com when
this Statement is changed.
- Other Policies
Suply HotSpot has other policies that may be applicable to
personal information, including the website Privacy Policy.
- Contact Information
If you have any questions about this Statement, please contact us by e-mail at support@suplyhotspot.com.